One sure way of confirming a phase-in substance

 Prior to importing a non-phase-in substance,  its importer shall complete one of the following under the ACT ON REGISTRATION AND EVALUATION OF CHEMICAL SUBSTANCES (화학물질의 등록 및 평가 등에 관한 법률):

-        Registration

-        Reporting

-        Confirmation of exemption from registration

-        Confirmation of exemption from reporting

 

If the result of search with CAS No. of the chemical substance in the Chemical Substance Information Process System (https://kreach.me.go.kr/repwrt/mttr/en/mttrList.do) shows KE No., we can confidently say it is a phase-in substance. However, what if the search result is blank? Does it mean that the searched chemical substance is a non-phase-in substance? The answer is not necessarily yes. Because the searched chemical substance can be a variant of a phase-in substance.

 

There are three categories of phase-in substance variants, which are also deemed as a phase-in substance.

A. Isotope

A phase-in substance variant with isotopes is a phase-in substance. For example, Bromobenzene-d5 (CAS No. 4165-57-5) is a phase-in substance because Bromobenzene (CAS No. 108-86-1) is a phase-in substance (KE No. KE-03624).


B. Hydrate

A hydrated phase-in substance is a phase-in substance. For example, D-Lactose monohydrate (CAS No. 64044-51-5) is a phase-in substance because beta-Lactose (CAS No. 63-42-3) is a phase-in substance (KE No. KE-17416).

 


C. Stereostructure

A phase-in substance variant of stereostructure is a phase-in substance. For example, Ibotenic acid, (R)- (CAS No. 25690-46-4) and Ibotenic acid, (S)- (CAS No. 25690-45-3) are phase-in substances because Ibotenic acid (CAS No. 2552-55-8) is a phase-in substance (KE No. KE-05-0773).

 

It can be difficult to find the correct CAS No. of the relevant basic chemical substance to search for in the NCIS. If a renowned chemical substance information site like the PubChem (https://pubchem.ncbi.nlm.nih.gov/) provides structure data, we may find the relevant basic chemical substance using “Find Similar Structures” function, comparing the structure of a chemical substance in question with the structures of search result. However, there are numerous chemical substances, and it can be difficult to locate the basic chemical substance with certainty.

 

One sure way of confirming whether a chemical substance in question is a phase-in substance is to use the confirmation of exemption from reporting (CER). The application for CER can be filed for a chemical substance for scientific experiment, analysis or research, such as reagents by attaching documents about product information and Material Safety Data Sheet or Letter of Confirmation (including CAS No. information) for the chemical substance in question.

 

After reviewing the submitted documents, if the chemical substance for which the application has been filed is a phase-in substance, the Korea Environment Corporation gives the result notice with the basic chemical substance indicated, saying that the chemical substance is a phase-in substance and not subject to the confirmation of exemption from registration unless 1 ton or more is imported.

 

The processing fee of CER is KRW 30,000. Considering that the uncertainty concerning the determination of phase-in substance is completely removed, it may be worth it.

 

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